PBM Compensation and Fee Disclosure

This document is the testimony of David Balto, a public interest and antitrust attorney, before the ERISA Advisory Council on the need to extend compensation and fee disclosure requirements under ERISA Section 408(b)(2) to welfare benefit plans and pharmacy benefit managers (PBMs). Balto argues that greater disclosure is needed to address the lack of transparency and conflicts of interest in the PBM industry, which has led to deceptive practices and higher costs for plans and consumers.